Companies in scope of the European Union (EU) Waste Framework Directive (WFD) are unlikely to get any additional time to prepare for their submissions to the Substances of Concern as such, or in complex articles (Products) (SCIP) database, says the European Chemicals Agency (ECHA).

Although the ECHA has received feedback regarding the difficulty of meeting the EU WFD’s more data-heavy requirements, it asserted that companies have had adequate time to meet these requirements.

“REACH Article 33 is an equivalent duty that has been in place for over ten years,” ECHA told Chemical Watch.

The European Commission concurred.

“The Commission continues to encourage companies to do what is possible to fulfill their legal obligations…they still have a number of months to prepare for the SCIP database notification obligation.”

While true that some companies in scope of the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation already have some systems in place for meeting Article 33 communication requirements, they also need to collect, generate, and map new article data to complete their SCIP submissions.

They can then submit the data to the SCIP database either online, offline, or through a system-to-system transmission. Even if they already have REACH data, companies need expertise, process, and control systems to acquire and manage the additional EU WFD data, and create secure article dossiers that won’t reveal proprietary information. Doing this properly can create a business advantage when evaluators access the SCIP database and find your complete dossiers, but none from your competitors.

Need help in mounting an effective response to these requirements? Get more information in our guide, Building a SCIP Database Program.

What This Means for Your Company

The pressure on companies to report on substances of very high concern (SVHCs) continues to build. Just five days before the January 5, 2021, SCIP database deadline, the EU Market Surveillance Regulation will come into effect. Using the Union Product Compliance Network database, market surveillance agencies will be able to access centralized enforcement data from all member states. They will also gain access to the SCIP database, allowing them to zero in on non-compliant articles placed on the EU single market.

You’ll need more data from your suppliers to respond to the data requests you’re going to get from any company hoping to avoid this enforcement, and your competitors will need to follow suit to keep pace.

Assent facilitates data exchange by providing small and medium-sized businesses free access to our SCIP Registration Center. This allows them to continue selling products to manufacturers with heavy data needs without creating a data burden that negatively impacting profit for either company, and helps our larger clients access some of the missing pieces in their own dossiers.

Meanwhile, Assent is helping the world’s largest enterprises manage the data they need to meet these requirements. We provide the regulatory expertise to verify the efficacy of your program, the support to manage your program should you need it, and the expertise to help your program effortlessly scale with new technology requirements such as the SCIP database submissions.

To learn more, contact our experts at

James Calder
SVP, Strategic Channels & Corporate Development

James leads the Corporate Development function at Assent, creating and executing on strategies to increase strategic partnerships and channel sales, and identify growth opportunities through mergers  Read More

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